The new economic policy chapter reflects the suggestions of the business community, so it is important that the voices of other stakeholders be heard. If you are reading this after the hearing, do not worry. There will be another public hearing before the city council. You can submit comments to the city and planning commission at planningcommission@cob.organd planning@cob.org.

I have highlighted some of the issues I found concerning:

Natural Resources

The draft chapter identifies wetlands and critical areas as a threat to jobs by preventing expansion of development. A healthy environment is a prerequisite to economic sustainability and this should be reflected in COB economic development policy. Wetlands and critical areas have important value in our community because they protect environmental and human health, quality of life and economic vitality. The city should support the regulatory requirement to protect critical areas, and focus instead on the real reasons behind a weak economy and a high level of income disparity.

There are two new policies that are specifically troubling. Policy ED-20 recommends mitigation for any actions by city council that reduce “lost employment land capacity.”Mitigation replaces the ecological function and value of critical areas.It is not applicable to jobs and employment.And “employment land" is a concept fabricated by the city that has no reference or meaning under the GMA. The city should not use terms that are meaningless and confusing. Instead, we have urban land and UGAs zoned for commercial, industrial and mixed use. This is, therefore, an attempt to mitigate a zoning designation. Zoning is based on public needs, and it changes as public needs change. Because zoning is not permanent and fixed, it can not be “mitigated” when it is amended.

Policy ED-26 requires investigating a regional approach to stormwater and wetland mitigation to “reduce costs for individual businesses.”Creating off-site compensatory mitigation projects require time, money, a great deal of analysis and planning, and amendment of the city's Critical Area Ordinance. And even then, they often fail because they attempt to recreate ecological function, rather than preserve what already exists. Moreover, the purpose of mitigation is to avoid and replace impacts to ecologic function, rather than to reduce business costs.Under city code, “mitigation site selection shall be focused on the site’s ability to sustain a Critical Area over the long term.” BMC 16.55.240.

Role of City Government

I believe an important policy change is quietly being made. The new ED draft expands the city’s role in economic development so that a primary duty becomes the promotion of business interests. See Section II, the City’s Role in Economic Development, and policies ED-1, 2, 3, 4,7,8,10.The new policies encourage the city to partner with business associations, and other agencies in Whatcom County, to enhance economic opportunity, reduce regulatory restrictions, and increase business incentive. Quality of life is defined in terms of a variety of job opportunities, an expanding tax base, incentives for business, and more and more growth.

I do not believe this reflects public values, as reflected in the 2009 Legacies and Strategic Commitment. The private sector should be primarily responsible for creating economic opportunity in Whatcom County. The responsibility of local government is to assure that economic development activities are carried out in a manner that is consistent with defined community and environmental values.The government should focus on reducing use and dependency on fossil fuels and other natural resources that are finite and environmentally harmful. And it should not blindly accept the fact that more and more growth is always good.

Economic Justice

The GMA goal for economic development focuses on economic opportunity for all citizens of the state, especially the unemployed and disadvantaged.RCW 36.70A.020(5). There is no policy goal that reflects this, even though the city residents recently passed a low-income housing levy.The 2009 Legacies and Strategic Commitment contained a commitment for equity and social justice.Let’s see that reflected in our new economic development policy chapter.

Conclusion

I recommend you review this draft document to determine if there are other policies you consider important. For example, if you have concerns about airport expansion, a new policy reflects city support for this port project. Because this is an amendment to the city comprehensive plan, it forms important policy that guides development regulations.

Alex McLean //Fri, Feb 15, 2013, 4:32 pm

Hi Wendy,

Thanks for your usual tenacity in covering these slithering and slippery changes to code processes, mitigation requirements, and environmental safeguards in general. The byzantine stew of overlapping regulations seems to mean that, at any point, a subtle tweak here or there can gut the entire intent of protections that were fought for, and earned, for good reason.

I am of course still embittered by the fact that my tax dollars, under the duly elected authority of our new MPD, will be used to bail-out development rights in the Chuckanut Community Forest in zones where no sane critic could proclaim that wetlands would have been impacted. I’ll have ten years to ponder that outlay of my personal finances for that cause and, eventually, will get over it.

That said, this proposal that you describe above seems far more directly tied to empowering developers to saunter into wetlands and “mitigate” them into oblivion. Demonizing environmental policy as “a threat to jobs” and then codifying that as a justification for ignoring a well-established environmental policy reeks of the same “employment vs. environment” Trojan horse that has been played out by developers since the dawn of time.

I hope our planners do not fall for it and, as implied, I look forward to supporting your efforts to thwart this serious problem despite the success of your far less important and distracting last campaign.